The Energy Storage Association (“ESA”) submits comments in response to a letter dated October 1, 2014 from Heather Curlee and Eugene Bernstein representing Commonwealth Edison Company (“ComEd”) on the issue of developing a tariff to address wholesale distribution charges of an energy storage project.

ESA believes that energy storage assets connected to the distribution system that are solely storing electricity to return to the grid at a later time--providing transmission or distribution services, peak capacity, or other ancillary services to the utility--should be able to charge at wholesale electricity market rather than at retail prices. Further, energy storage assets should not be allocated any transmission or distribution demand charges that are not paid by traditional supply resources providing the same services to the grid.